HB 2273
In CommitteeHouse
Embodied carbon/buildings
Reducing embodied carbon emissions of buildings and building materials.
This status may be delayed. See Action History below for the latest updates.
How does a bill become law?
- Introduced: The bill is filed and assigned a number.
- Committee: A subject-matter committee holds hearings, takes public testimony, and decides whether to advance the bill.
- Floor Vote: The full chamber (House or Senate) debates and votes on the bill.
- Opposite Chamber: The bill repeats the committee and floor vote process in the other chamber.
- Governor: The Governor reviews the bill and decides whether to sign or veto it.
- Signed: The bill has been signed into law.
AI Analysis
This bill sets mandatory targets to reduce embodied carbon emissions—the greenhouse gases released during material production and construction—for large new buildings and renovations in Washington. It gives builders three ways to comply: reuse existing structures, use lower-carbon materials with verified data, or demonstrate overall building-level reductions through life-cycle analysis. The law also creates a public database to track progress and requires state agencies to support implementation with tools and audits.
- Requires new construction, additions, and renovations of 100,000 square feet or larger (excluding school districts) to reduce embodied carbon emissions by 30% by 2030, using one of three compliance pathways.
- Pathway 1: Preserve at least 45% of an existing building’s structure and envelope without adding more than 50% to the total area.
- Pathway 2: Reduce A1–A3 life-cycle emissions (extraction, manufacturing, transport) for 90% of covered materials using product- and facility-specific environmental product declarations.
- Pathway 3: Conduct a whole building life-cycle assessment comparing the project to a functionally equivalent reference building, using internationally recognized standards (e.g., ISO 21931-1).
- Requires submission of project data—including compliance pathway, materials, and structural system—into a public database maintained by the Department of Commerce, with annual audits of 3% of projects.
- Mandates that the State Building Code Council adopt rules by the 2024, 2027, and 2030 code cycles, with incremental steps toward the 30% reduction target, and report progress every three years.
Who is affected
- Building owners and developers of large non-residential projects — Must comply with new embodied carbon reduction requirements for new construction, additions, or renovations of 100,000 square feet or larger (excluding school districts), including selecting one of three compliance pathways and submitting reporting data.
- Architects and engineers (design professionals of record) — Must use project-specific environmental product declarations and verify calculations for covered materials, and submit attested compliance documentation before project completion.
- Department of Commerce — Must maintain a public database of project-level embodied carbon data, conduct annual audits, and create educational resources to support compliance.
- State Building Code Council — Must adopt new rules and standards for reducing embodied carbon in buildings, consult with state agencies and experts, and report progress on implementation.
Pro/Con Analysis
Stronger case for benefits
Potential Benefits (5)
Requiring reuse of at least 45% of an existing building’s structure and envelope significantly reduces demolition waste and avoids the high embodied carbon of new construction, directly lowering regional GHG emissions and supporting circular economy principles.
EnvironmentPeopleRef: Sec. 2(1), Sec. 8(1)Mandating facility-specific EPDs for 90% of covered materials drives transparency and accountability in the building supply chain, incentivizing manufacturers to reduce emissions and enabling data-driven decarbonization across the industry.
EnvironmentPeopleRef: Sec. 3(1)(a), Sec. 8(1)The public database and educational resources created by the Department of Commerce will democratize access to embodied carbon data and best practices, supporting workforce training, academic research, and informed decision-making for developers, designers, and the public.
EducationPeopleRef: Sec. 5(1), Sec. 5(2)(a)-(f)The whole-building life-cycle assessment pathway encourages integrated design and holistic carbon reduction—beyond just materials—by requiring comparison to a functionally equivalent reference building, promoting energy-efficient building performance and long-term sustainability.
EnvironmentPeopleRef: Sec. 4(1), Sec. 8(1)The incremental, code-cycle-based implementation (2024, 2027, 2030) and ability to refine standards over time based on data collection allows the market to adapt gradually, reducing shock to the construction industry while ensuring long-term decarbonization.
Business & EmploymentPeopleRef: Sec. 8(3), Sec. 1(3)
Potential Concerns (5)
The 100,000-square-foot threshold excludes most small- and mid-sized commercial projects, but for those above the threshold, compliance will increase design and material costs—potentially delaying or canceling projects—especially in regions with limited supply chains for low-carbon materials.
Business & EmploymentIndustryRef: Sec. 1(2), Sec. 8(1)Architects, engineers, and sustainability consultants will face new liability exposure and documentation burdens (e.g., attestation of as-built material quantities and EPDs), increasing professional liability insurance costs and requiring new training or hiring of specialists.
Business & EmploymentIndustryRef: Sec. 3(1)(c), Sec. 4(3), Sec. 5(2)Material suppliers and manufacturers—especially those outside Washington—must now provide facility-specific environmental product declarations (EPDs), which are costly to produce and may limit market access for smaller producers unable to afford third-party certification.
Business & EmploymentIndustryRef: Sec. 3(1)(a), Sec. 3(1)(b), Sec. 4(2)Local building departments and permitting offices will face increased administrative burden verifying compliance documentation and coordinating with the Department of Commerce’s database, without explicit funding to offset these added responsibilities.
Local GovernmentLean industryRef: Sec. 5(1), Sec. 5(2)(c)The requirement for facility-specific EPDs may reduce supply chain flexibility and increase material costs—particularly for regional or specialty materials—potentially inflating project budgets and reducing affordability of large non-residential construction.
Business & EmploymentIndustryRef: Sec. 3(1)(a), Sec. 8(2)
Who Is Most Affected
Large non-residential developers and building owners will face higher upfront design and material costs, but may benefit from long-term energy savings and market differentiation as sustainability becomes a premium feature. However, smaller developers below the 100k sq ft threshold are exempt and may gain competitive advantage in the affordable housing or small commercial markets.
Architects and engineers will incur new compliance, documentation, and liability costs, but also gain professional credibility and market differentiation in a growing sustainability-focused sector. Firms with in-house sustainability expertise will be best positioned to thrive.
Material suppliers—especially those producing high-embodied-carbon products like concrete and steel—face pressure to innovate or lose market share. Conversely, producers of low-carbon alternatives (e.g., mass timber, recycled steel, low-carbon concrete) stand to gain significant new demand and pricing power.
Local governments will gain a powerful new tool to meet state climate goals and support green infrastructure, but may face increased permitting workload and technical capacity gaps without dedicated funding. The public database may also reduce their need for independent carbon modeling.
Washington residents benefit indirectly through reduced climate risk, improved air quality, and long-term energy savings from more efficient buildings. However, if construction costs rise significantly, this could indirectly increase rents or commercial lease rates in high-demand markets.